On Friday October 31, 2025, the Energy Facilities Siting Board (EFSB) and the Office of Environmental Justice and Equity (OEJE) released the long awaited draft Cumulative Impact Analysis and Standards for Applying Site Suitability Criteria (980 CMR 15.00) and Draft Standards and Guidelines for Cumulative Impact Analysis1. These documents outline a regulatory framework for assessing environmental, health, and socioeconomic burdens associated with energy infrastructure projects, particularly those sited in environmentally burdened communities.
Purpose and Context
The Cumulative Impact Analysis (CIA) Regulations and Guidelines are a part of the development of siting and permitting reforms mandated by the 2024 Climate Act(M.G.L. c.164 §69G), which require applicants for certain energy facilities to assess cumulative environmental and public health impacts within a Specific Geographical Area (SGA). The guidance is meant to ensure equitable distribution of clean energy benefits and the prevention of disproportionate adverse impacts on burdened areas. The regulations and oversight are a joint effort of EFSB, OEJE, the Department of Public Utilities (DPU) and the Department of Energy resources (DOER).
Regulatory Objectives
- Integrate cumulative impact analysis into EFSB siting and permitting decisions.
- Require transparent, data-driven evaluations of environmental and public health effects.
- Align Massachusetts’ clean energy transition with environmental justice and equity principles.
- Ensure that community input meaningfully shapes outcomes.
MassEnviroScreen Tool
To accomplish the regulatory objectives OEJE developed the MassEnviroScreenTool, whichis a GIS-based platform used to identify and rank community vulnerability across Massachusetts. It scores every Census Block Group using 30 indicators across five categories—environmental exposures, effects, climate risks, sensitive populations, and socioeconomic factors. Areas at or above the 75th percentile based on the aggregate score, or with median household income below 65% of the state median are designated as Burdened Areas (BA). This tool is an integral part of the CIA process, providing a quantitative benchmark for identifying and prioritizing BAs across Massachusetts.
The CIA Process
Applicants proposing projects within or near a BA must perform a CIA before filing with EFSB. The process involves:
- Identify the Specific Geographical Area (SGA): Defined by project type and distance radius from the project location (¼ to 5 miles).
- Determine Overlap with Burdened Areas: MassEnviroScreen is used to identify affected Census Blocks Groups within the SGA.
- Catalog Indicators: Baseline conditions are then compiled for all indicators; indicators that are at or above the 50th percentile are flagged as “Elevated Indicators”.
- Assess Impacts: Determine whether the project exacerbates or improves Elevated Indicators.
- Apply Mitigation Hierarchy:
- Avoid negative impacts where feasible
- Minimize unavoidable effects
- Mitigate remaining impacts through on- or off-site measures.
Community Engagement
Meaningful and early engagement is central to the CIA framework. Applicants must ensure communication is accessible, continuous throughout the CIA process, and culturally sensitive. Qualitative data—including community testimonies and stakeholder input— should complement quantitative analyses. CIA findings should be shared in clear, and accessible manner, considering any needed translations of materials and visual formats.
Community Benefit Plans (CBPs)
CBPs, whether enforceable or non-enforceable, are not required by the draft regulations. However, applicants are strongly encouraged to consider CBPs as an additional way to support local benefits in host communities. CBPs are separate from project mitigation requirements and are not intended to replace or substitute for any required avoidance, minimization, or compensatory mitigation measures.
Regulatory Integration and Accountability
CIA findings will be used to inform EFSB’s siting and permitting decisions. Projects must demonstrate avoidance of disproportionate impacts, incorporate mitigation plans, and document community engagement outcomes. The process is meant to advance the Commonwealth’s goals for a just, sustainable energy transition.
Key Takeaways
Following promulgation of the draft regulations, CIA will be a required component of clean energy infrastructure siting in Massachusetts.
MassEnviroScreen Tool will be used to identify BAs, catalog baseline conditions, and assess whether project impacts would affect any elevated community indicators.
Early, meaningful community involvement will be an integral part of the CIA process.
EFSB decisions will consider CIA findings in approving, conditioning, or denying project permits.
1 See: Energy Infrastructure Siting and Permitting Reforms | Mass.gov
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About the Expert
Sonja Sax, Sc.D, is an environmental health scientist in Epsilon’s Air Quality Group. Dr. Sax specializes in evaluating exposure and health risk from environmental pollutants. She has over 20 years of experience in environmental regulatory assessment, health impact assessment and cost-benefit analyses. She has managed large multi-year projects advocating for clients involved in litigation or providing permitting support. She has performed indoor and outdoor air quality investigations evaluating exposures and health impacts of airborne gases and particles. She also served as a consultant to the US EPA Clean Air Scientific Advisory Committee for the particulate matter and ozone National Ambient Air Quality Standards. More recently she has worked on projects of all sizes conducting Environmental Justice analyses, modeling of air quality impacts and providing guidance to clients on the best approaches for addressing new EJ regulations in multiple states, including Massachusetts and New Jersey.